Policy on Personal Data Processing

Scientific-Production Limited Liability Company "Sinergia", as a commercial enterprise, fully understands that our most valuable asset is our customers.

That is why it is crucial not only to offer optimal solutions for your packaging needs, but also to ensure a secure informational environment—from initial contact to ongoing collaboration.

As part of our commitment to security, we have developed and approved this Policy on Personal Data Processing (hereinafter referred to as the "Policy").

This Policy explains how and why your personal data is collected, used, or otherwise processed, and outlines your rights and how to exercise them.

1. Legal Definition and Processing Purposes
According to the legislation of the Republic of Belarus, personal data refers to any information that directly or indirectly identifies an individual (e.g., full name, passport details, phone number, geolocation, etc.).

Like many companies, “Sinergia” collects and processes personal data in order to:

Execute civil law contracts (e.g., supply, purchase and sale, service agreements)

1. Legal Definition and Processing Purposes

According to the legislation of the Republic of Belarus, personal data refers to any information that directly or indirectly identifies an individual (e.g., full name, passport details, phone number, geolocation, etc.).

Like many companies, “Sinergia” collects and processes personal data in order to:

• Execute civil law contracts (e.g., supply, purchase and sale, service agreements)

Subjects of data processing: 

• Authorized representatives signing contracts

Types of data collected: 

• Full name or initials, job title, and other data as required by contract terms

Legal basis for processing:

• Contracts with individuals: based on the subject’s consent (Article 6, Paragraph 15)

Contracts with legal entities: 

• based on legal obligations (Article 6, Paragraph 20; Civil Code Article 49, Point 5 of Article 186)

Retention period:

• 3 years after contract expiration and tax inspection
• 10 years if no inspection occurs

2. Handling Public Inquiries and Complaint Logs

Subjects of data processing: 

• Individuals submitting inquiries or listed in them

Types of data collected: 

• Full name, address, inquiry content, and other personal data mentioned

Legal basis for processing: 

• Necessary to fulfill legal obligations (Article 6, Paragraph 20; Law on Citizens’ and Legal Entities’ Appeals)

Retention period:

• 5 years from last inquiry
• 5 years after closing the complaint logbook

3. Processing Resumes and Job Applications

Subjects of data processing: 

• Individuals submitting applications for employment

Types of data collected: 

• All personal data included in CVs, forms, autobiographies, recommendation letters, etc.

Legal basis for processing:

• Online submission: explicit consent

Written or digital submissions: 

• Article 6, Paragraph 16

Retention period:

• 1 year (if not hired)
• 1 month (if hired)

4. Use of Video Surveillance for Public Safety

Subjects of data processing: 

• Visitors to office and warehouse facilities

Types of data collected: 

• Visual image of individuals

Legal basis for processing:

• Presidential Decree No. 527 (2013) and Council of Ministers Resolution No. 1135 (2012)

Retention period: 

• 30 days

5. Anonymized Data for Research and Publications

Personal data may be anonymized and used for research purposes, including informational articles or seminar reports related to packaging equipment in the company’s demo hall.

6. Commitment to Data Protection

We pledge to:

• Process only necessary personal data
• Avoid excessive data collection
• Not share data with third parties unless required by law

7. Your Rights as a Data Subject

You may:

• Withdraw consent at any time
• Request details about processing: 
  • operator name/location, legal grounds, processing purpose, data source, and more
• Request updates or corrections to inaccurate or outdated data

• Ask whether your data has been shared with third parties (once annually, free of charge)

• Demand cessation of processing and data deletion if legally unjustified

• File a complaint if your rights are violated during processing

8. How to Exercise Your Rights

Please submit a written or electronic request (in the same format as consent was given) to LLC “Sinergia” at the official mailing address or online address.

Your request must include:

• Full name and address
• Date of birth
• Description of your request
• Identification number or ID details (if previously provided)
• Signature (handwritten or digital)

Please note: requests submitted by phone, fax, or email are not accepted.

You may also contact the internal data protection officer by emailing jurist1@sinergia.by.